General Note on the Standard Ag/Med GLs for List-based Blocking Programs (System Ed. Note)

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TURBOFAC Commentary (2153 words)

General Note on the Standard Ag/Med GLs for List-based Blocking Programs (System Ed. Note)

1) BACKGROUND

On 12-21-22 OFAC added 29 substantively identical GLs to list-based blocking programs. The GLs, entitled, “Transactions related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for personal, non- commercial use” (the “Individual Use Ag/Med GLs”) are unique in some respects, and similar to OFAC’s other ag/med-related GLs in others. Refer to “Treasury Implements Historic Humanitarian Sanctions Exceptions” (Press Release) (https://home.treasury.gov/news/press-releases/jy1175) (“Treasury is issuing these GLs across sanctions programs that did not previously have humanitarian exceptions, implementing a new standardized baseline set of authorizations across OFAC-administered programs.”) . Note that OFAC did not implement the ag/med GL in the Burma program (part 525). There is a substantial chance that this was an oversight.

Apart from...